Appendix A: Respondents and Agency Activities Table

Table A1. Respondents Activities table (permittees)

Activity Description Respondent Type

Total 

Hours 

per 

respons

e

capital / 

startup 

cost

O&M 

Cost

Total 

Annualized 

Captial and 

O&M Cost

Total Number 

of 

Respondents

Annual 

Number of 

Respondents Frequency of Reporting

Number 

of 

Respon

ses / 

respond

ent / yr

Number of 

Responses Year

Total Hours 

/ Year Total Labor Cost

Type of 

Activitity OMB 

(Reporting / 

Recordkeepin

g / 3rd party 

disclosure)

Type of Activity (EPA 

classification)

Obligation of 

Response 

OMB 

(mandatory, 

voluntary) Affected Public (OMB)

NOI preparation & submittal operators - PGP Table 1-1 2 $0 $0 $0 9,125 1,825 once every 5 yrs 1 1,825 3,650 $299,300 Reporting 1. Application/NOI mandatory Business, other for-profit, government

NOI preparation & submittal operators under PGP - informal ESA 6 $0 $0 $0 37 7 once every 5 yrs 1 7 44 $3,641 Reporting 1. Application/NOI mandatory Business, other for-profit, government

NOI preparation & submittal operators under PGP - formal ESA 20 $0 $0 $0 18 4 once every 5 yrs 1 4 73 $5,986 Reporting 1. Application/NOI mandatory Business, other for-profit, government

NOT Preparation & submittal operators - PGP Table 1-1 (all) 0.5 $0 $0 $0 456 91 once 1 91 46 $5,156 Reporting 1. Application/NOI mandatory Business, other for-profit, government

Develop PDMP operators - NOI filers (large) 40 $0 $0 $0 4,836 967 once every 5 yrs 1 967 38,690 $2,073,784 Reporting 2. Plan Development mandatory Business, other for-profit, government

Update PDMP operators - NOI filers (large) 2 $0 $0 $0 4,836 1,209 ongoing 1 1,209 2,418 $123,324 Reporting 2. Plan Development mandatory Business, other for-profit, government

Monitoring (large site) operators - NOI filers (large) 0.25 $0 $0 $0 4,836 4,836 ongoing 16 77,380 19,345 $986,595 Reporting 3. Monitoring mandatory Business, other for-profit, government

Monitoring (small site) operators - NOI filers (small) 0.25 $0 $0 $0 4,289 4,289 ongoing 4 17,155 4,289 $218,726 Reporting 3. Monitoring mandatory Business, other for-profit, government

Monitoring other operators 0.25 $0 $0 $0 355,875 355,875 ongoing 1 355,875 88,969 $4,537,406 Reporting 3. Monitoring mandatory Business, other for-profit, government

Annual Report preparation & submittal operators - NOI filers (large & ESA) 8 $0 $0 $0 4,892 4,892 yearly 1 4,892 39,132 $1,995,732 Reporting 4. Reporting mandatory Business, other for-profit, government

Adverse Incident Documentation all operators 2 $0 $0 $0 365,000 37 occasionally/As Needed 1 37 73 $3,723 Reporting 4. Reporting mandatory Business, other for-profit, government

Adverse Incident verbal notification all operators 2 $0 $0 $0 365,000 37 occasionally/As Needed 1 37 73 $3,723 Reporting 4. Reporting mandatory Business, other for-profit, government

Adverse Incident to Threatened or Endangered Species all operators 2 $0 $0 $0 365,000 4 occasionally/As Needed 1 4 7 $372 Reporting 4. Reporting mandatory Business, other for-profit, government

Spill, Leak verbal notification all operators 0 $0 $0 $0 365,000 365 occasionally/As Needed 1 365 0 $0 Reporting 4. Reporting mandatory Business, other for-profit, government

Spill, Leaks Documentation all operators 1 $0 $0 $0 365,000 365 occasionally/As Needed 1 365 365 $18,615 recordkeeping 5. Recordkeeping mandatory Business, other for-profit, government

Corrective Action Documentation all operators 5 $0 $0 $0 365,000 365 occasionally/As Needed 1 365 1,825 $93,075 recordkeeping 5. Recordkeeping mandatory Business, other for-profit, government

Permittee Report of Planned Facility Changes all operators 4 $0 $0 $0 365,000 365 occasionally/As Needed 1 365 1,460 $74,460 Reporting 4. Reporting mandatory Business, other for-profit, government

Permittee Report of anticipated noncompliance all operators 5 $0 $0 $0 365,000 365 occasionally/As Needed 1 365 1,825 $93,075 Reporting 4. Reporting mandatory Business, other for-profit, government

Permittee Report of Inaccurate Previous Information all operators 2 $0 $0 $0 365,000 183 occasionally/As Needed 1 183 366 $18,666 Reporting 4. Reporting mandatory Business, other for-profit, government

Noncompliance Reports all operators 5 $0 $0 $0 365,000 183 occasionally/As Needed 1 183 915 $46,665 Reporting 4. Reporting mandatory Business, other for-profit, government

Recordkeeping (basic) all operators 1 $0 $0 $0 365,000 365,000 ongoing 1 365,000 365,000 $14,965,000 recordkeeping 5. Recordkeeping mandatory Business, other for-profit, government

Recordkeeping operators - non-NOI filers 0.5 $0 $0 $0 355,875 355,875 ongoing 1 355,875 177,938 $9,074,813 recordkeeping 5. Recordkeeping mandatory Business, other for-profit, government

Full Recordkeeping operators - NOI filers (large) 1 $0 $0 $0 4,836 4,836 ongoing 16 77,380 77,380 $3,946,380 recordkeeping 5. Recordkeeping mandatory Business, other for-profit, government

Recordkeeping (PDEW) operators - NOI filers (small) 1 $0 $0 $0 4,289 4,289 ongoing 4 17,155 17,155 $9,195,080 recordkeeping 5. Recordkeeping mandatory Business, other for-profit, government

TOTAL 1,277,083 841,037 $47,783,297

1. Total hours per response are from the EA or ICR for NPDES Program except for the Update PDMP.

3. Annual number of respondents: total divide by 5 for NOI, NOT, PDMP (5-year permit cycle): update plans - assumed 25%; adverse incident - assumed 0.01%; adverse incident to TES - assumed 0.001%; report of anticipated noncompliance & inaccurate previous info - assumed 0.05%; others - assumed 0.1%

2. Total number of respondents: assumed 2.5% of 365,000 respondents are required to submit NOIs; assumed 0.1% of 36,500 respondent will need to address ESA informally and 0.05% formally; assumed 5% of the respondents required to submit NOIs will file NOT; assumed 47% of the respondents required to submit NOIs are small entities and 53% are 

large entities; assumed respondent with ESA issue will submit annual reports.

4. Total Labor rate: used same rate as those in the EA - average managersial rate $113, technical rate $51, clerical rate $41. NOI (50% managerial, 50% technical); NOT (all managerial); PDMP (2hr managerials, 36hr technical, 2hr clerical); PDEW (0.5hr managerials, 9hr technical, 0.5hr clerical); other activities (technical rate or clerical rate)

September 2011
Appendix A: Respondents and Agency Activities Table

Table A2. Respondents Activities table (States)

Activity Description Respondent Type

Total 

Hours 

per 

respons

e

capital / 

startup 

cost

O&M 

Cost

Total 

Annualized 

Captial and 

O&M Cost

Total Number 

of 

Respondents

Annual 

Number of 

Respondents Frequency of Reporting

Number 

of 

Respon

ses / 

respond

ent /yr

Number of 

Responses Year

Total Hours 

/ Year Total Labor Cost

Type of 

Activitity OMB 

(Reporting / 

Recordkeepin

g / 3rd party 

disclosure)

Type of Activity (EPA 

classification)

Obligation of 

Response 

OMB 

(mandatory, 

voluntary) Affected Public (OMB)

NOI processing & review States 0.5 $0 $0 $0 45 45 every 5 yrs 36.5 1,643 821 $31,208 Reporting 1. Application/NOI mandatory States

NOT processing & review States 0.25 $0 $0 $0 45 45 ongoing 1.825 82 21 $780 Reporting 1. Application/NOI mandatory States

Annual Report processing & review States 1 $0 $0 $0 45 45 yearly 97.609 4,392 4,392 $166,911 Reporting 4. Reporting mandatory States

Adverse Incident report review States 2 $0 $0 $0 45 45 occasionally/As Needed 0.73 33 66 $2,497 Reporting 4. Reporting mandatory States

Permittee Report of Planned Facility Changes States 0.5 $0 $0 $0 45 45 occasionally/As Needed 7.3 329 164 $6,242 Reporting 4. Reporting mandatory States

Permittee Report of anticipated noncompliance States 2 $0 $0 $0 45 45 occasionally/As Needed 7.3 329 657 $24,966 Reporting 4. Reporting mandatory States

Permittee Report of Inaccurate Previous Information States 1 $0 $0 $0 45 45 occasionally/As Needed 3.66 165 165 $6,259 Reporting 4. Reporting mandatory States

Noncompliance Reports States 2 $0 $0 $0 45 45 occasionally/As Needed 3.66 165 329 $12,517 Reporting 4. Reporting mandatory States

TOTAL 7,136 6,615 $251,379

Table A3. Agency Activities Tabel

Activity Description Respondent Type

Total 

Hours 

per 

respons

e

capital / 

startup 

cost

O&M 

Cost

Total 

Annualized 

Captial and 

O&M Cost

Total Number 

of 

Respondents

Annual 

Number of 

Respondents Frequency of Reporting

Number 

of 

Respon

ses / 

respond

ent /yr

Number of 

Responses Year

Total Hours 

/ Year Total Labor Cost

Type of 

Activitity OMB 

(Reporting / 

Recordkeepin

g / 3rd party 

disclosure)

Type of Activity (EPA 

classification)

Obligation of 

Response 

OMB 

(mandatory, 

voluntary) Affected Public (OMB)

NOI processing & review EPA 0.5 once every 5 yrs 183 91 $3,737 Reporting 1. Application/NOI mandatory EPA

NOI processing & review (informal) Services 0.5 occasionally/As Needed 7 4 $152 Reporting 1. Application/NOI mandatory Services

NOI processing & review (formal) Services 5 occasionally/As Needed 4 18 $747 Reporting 1. Application/NOI mandatory Services

NOT processing & review EPA 0.25 ongoing 9 2 $93 Reporting 1. Application/NOI mandatory EPA

Annual Report processing & review EPA 1 yearly 500 500 $20,483 Reporting 4. Reporting mandatory EPA

Adverse Incident report review EPA 2 occasionally/As Needed 4 7 $299 Reporting 4. Reporting mandatory EPA

Adverse Incident to Threatened or Endangered Species Services 2 occasionally/As Needed 4 7 $299 Reporting 4. Reporting mandatory Services

Permittee Report of Planned Facility Changes EPA 0.5 occasionally/As Needed 37 18 $747 Reporting 4. Reporting mandatory EPA

Permittee Report of anticipated noncompliance EPA 2 occasionally/As Needed 37 73 $2,989 Reporting 4. Reporting mandatory EPA

Permittee Report of Inaccurate Previous Information EPA 1 occasionally/As Needed 18 18 $749 Reporting 4. Reporting mandatory EPA

Noncompliance Reports EPA 2 occasionally/As Needed 18 37 $1,499 Reporting 4. Reporting mandatory EPA

1. Total hours per response are from the ICR for NPDES Program. TOTAL 820 776 $31,795

2. Number of responses/yr - EPA is 10% of permittee's total number of responses/yr

3. Labor Rate for Federal is $40.95 and for State is $38.

September 2011